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SEC Comment Letter for GLADSTONE COMMERCIAL CORP (GOOD, GOODN, GOODO) (CIK 0001234006) (GOOD) — Jan 26, 2010

GLADSTONE COMMERCIAL CORP (GOOD, GOODN, GOODO) (CIK 0001234006)
Date: Jan. 26, 2010 · CIK: 0001234006 · Accession: 0000000000-10-004926

AI Filing Summary & Sentiment

File numbers found in text: 001-33097

Date
December 18, 2009
Author
Not clearly detected
Form
UPLOAD
Company
GLADSTONE COMMERCIAL CORP (GOOD, GOODN, GOODO) (CIK 0001234006)

Letter

Mail Stop 3010 December 18, 2009 Danielle Jones Chief Financial Officer Gladstone Commercial Corporation 1521 Westbranch Drive, Suite 200 Mclean, VA 22102 Re: Gladstone Commercial Corporation Form 10-K Filed February 25, 2009 File No. 001-33097

Dear Ms. Jones:

We have reviewed your filing and have the following comments. Where indicated, we think you should re vise your document in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as deta iled as necessary in your explanation. In some of our comments, we may ask you to provi de us with information so we may better understand your disclosure. After reviewing th is information, we may raise additional comments. Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.

General

1. We note that you appear to have used your old Exchange Act reporting number on the cover page of your Form 10-K and your most recent Form 10-Q. In future filings, please use your curre nt Exchange Act reporting number (001-33097) or advise.

Item 2. Properties, Page 22

2. Please provide us a schedule of leases expi ring in the next ten years, including the total area in square feet covered by such leases, the annual rental represented by

Danielle Jones Gladstone Commercial Corporation December 18, 2009 Page 2 such leases, and the percenta ge of gross annual rental represented by such leases on a portfolio basis. In addition, please tell us the geographic areas in which your properties are located on a portfolio basis. Confirm that you will provide similar disclosure in future filings.

*****

As appropriate, please amend your filing and respond to these comments within 10 business days or tell us when you will provid e us with a response. You may wish to provide us with marked copies of the amendm ent to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information. Detailed co ver letters greatly faci litate our review. Please understand that we may have addi tional comments after reviewing your amendment and responses to our comments. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under the Securities Exchange Act of 1934 and th at they have provided all information investors require for an informed invest ment decision. Since the company and its management are in possession of all facts re lating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that: • the company is responsible for the adequacy and accuracy of the disclosure in the filing;

• staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking a ny action with respect to the filing; and

• the company may not assert staff comme nts as a defense in any proceeding initiated by the Commission or any pers on under the federal s ecurities laws of the United States.

In addition, please be advise d that the Division of Enfo rcement has access to all information you provide to the staff of the Divi sion of Corporation Fi nance in our review of your filing or in response to our comments on your filing.

Danielle Jones Gladstone Commercial Corporation December 18, 2009 Page 3 Please contact Adam Turk at (202) 5 51-3657 or me at (202) 551-3401 with any questions. Sincerely,

Jennifer Gowetski Senior Counsel

Show Raw Text
Mail Stop 3010

        December 18, 2009
 Danielle Jones  Chief Financial Officer Gladstone Commercial Corporation 1521 Westbranch Drive, Suite 200 Mclean, VA  22102
Re: Gladstone Commercial Corporation  Form 10-K
Filed February 25, 2009
 File No. 001-33097

Dear Ms. Jones:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should re vise your document in response to these comments.  If
you disagree, we will consider your explanation as to why our comment is inapplicable or
a revision is unnecessary.  Please be as deta iled as necessary in your explanation.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.  After reviewing th is information, we may raise additional
comments.   Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

General

1. We note that you appear to have used your old Exchange Act reporting number on
the cover page of your Form 10-K and your most recent Form 10-Q.   In future
filings, please use your curre nt Exchange Act reporting number (001-33097) or
advise.

Item 2. Properties, Page 22

2. Please provide us a schedule of leases expi ring in the next ten years, including the
total area in square feet covered by such leases, the annual rental represented by

Danielle Jones
Gladstone Commercial Corporation
December 18, 2009 Page 2
such leases, and the percenta ge of gross annual rental represented by such leases
on a portfolio basis.  In addition, please tell us the geographic areas in which your
properties are located on a portfolio basis.  Confirm that you will provide similar disclosure in future filings.

*****

As appropriate, please amend your filing and respond to these comments within
10 business days or tell us when you will provid e us with a response.  You may wish to
provide us with marked copies of the amendm ent to expedite our review.  Please furnish
a cover letter with your amendment that keys your responses to our comments and provides any requested information.  Detailed co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing your
amendment and responses to our comments.   We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
  In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclosure in the filing;

• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking a ny action with respect to the filing;
and

• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any pers on under the federal s ecurities laws of
the United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

Danielle Jones
Gladstone Commercial Corporation December 18, 2009 Page 3
Please contact Adam Turk at (202) 5 51-3657 or me at (202) 551-3401 with any
questions.
Sincerely,

Jennifer Gowetski Senior Counsel